Air Quality and Stationary Source Emission Control (1975) / Chapter Skim
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12 Control of Ambient Sulfur Dioxide Concentrations with Tall Stacks and/or Intermittent Control Systems
12 Control of Ambient Sulfur Dioxide Concentrations with Tall Stacks and/or Intermittent Control Systems
Pages 485-538
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From page 485... ...
Not surprisingly, sulfur dioxide emission limitations for electric utility power plants varied widely In these plans. Much of the variation can be ascribed to regional fuel availability considerations, to state-imposed air quality standards or timetables, and to differing methodologies f or relating emissions and air quality.
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From page 487... ...
Temporal variations in emission limitations were not part of most states' implementation plans, except as part of emergency episode criteria. However, he situation here i-~roughly analogous-to the spatial variation situation.
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From page 488... ...
Tall stacks are closely associated with ICS programs, since increased :stack height can yield decreased needs for intermittent emission ; reductions, assuming that control of ambient sulfur dioxide concentrations.is the dole ob jective.
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From page 489... ...
FIGURE 12-1: Maximum Relative Concentration of SO2 as a Function of Meteorological Conditions and Stack Height (Carpenter et al.
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From page 490... ...
In the second approach, applicable where ambient sulfur dioxide standards cannot be met simply by increasing stack height, tall stacks are coupled with ICS measures to control ground-level sulfur dioxide concentrations. controversy has existed over whether tall stacks alone can adequately control ground-level sulfur dioxide concentrations.
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From page 491... ...
The closed-loop mode occurs when the open-loop node of operation has failed, i.e., when ambient air quality measurements exceed specified threshold values indoor AAQS. From the system diagram presented in Figure 12-2, ICS reliability and performance depend on a number of factors: {1} The adequacy and accuracy of monitoring the pertinent emissions, Air quality , and Meteorological parameters; {2} The ability to forecast meteorological inputs to the operating model, including; transition periods between different types of weather and potential interactions between meteorology and terrain; t3} m e adequacy of the air quality forecast model or models, which oust represent al} possible meteorological; conditions, account for terrain and location factors, and; estimate anticipated emission rates;
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From page 493... ...
... The suggestion that tall stacks be used with or without intermittent controls to meet sulfur dioxide standards is a.
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From page 494... ...
EPA, the 5th Circuit Court of Appeals held that the Clean Air Act requires Georgia to attain national ambient air standards primaril y through actual emission reductions rather than dispersion enhancement techniques; application of dispersion techniques is allowed only if exclusive reliance on emission control is infeasible (48a F
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From page 495... ...
Tn a February 1974 decision, -the court concluded that a flue gas scrubbing devicas.~.are available in theory only, and are not available and proven frown an operational or practical viewpoint.a A! Lawrence county, Pennsylvania court had prep viously determined that Hthe only conclusion to date...~s that the most feasible present method is high stack control.n Recently, a September 1974 Ohio EPA hearing exasuner' s report fav~ed the tall stackintermittent; control approach, stating that aflue gas ;des~f0zzation is not a presently available, technologically feasible method of sulfur dioxide control.,, H and but Stall stacks, either alone or in combination with supplementary control systems, are a technologically feasible and economically reasonable means of meeting ambient air quality standards for sulfur dio-xidea {Ohio EPA 1974~.
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From page 496... ...
Each of ~ e judicial or administrative decisions referred to above interprets requirements of the clean Air Act amendments of.1970~More recent legislation, ~ e Energy Supply and Environmental Coordination Act of 1974;lES~-ECA} {PL 93-319; enacted. by Congress June 24, 19741, provides further insight into Congressional intent regarding the implementation of EGO and tall i stack-ICS technologies.
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From page 497... ...
it-; ~i¢. i For the moment, hoverer, tall stacks and ICS measures are assumed to provide an important tec~Ol~ic~ OplLion,~ at We very least forreasons pointed out in EPA's - proposed regulations; {FR 1973~!
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From page 498... ...
Standards were exceeded prior- to September 1960 with a two-unit plant {two 704 MW generating units, each with a 600-foot stackI; capacity was increased by 82 percent- on September 19, 1969 by installation of- an 1150 unit with an 800-foot stack, with ICS measures also initiated to control high ground-level concentrations. ~ violations .of 3- or 24-hour AAQS have occurred at Me monitoring network since i~tiaticm of the T£S program, although four occasions An which sulfur dioxide concentrations were above the 3- ~ ur standard level have been noted; details concerning possible violations at non-monitored locations are not available.
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From page 500... ...
soo :1 it i to s4 0 4~ ~0 P4 en 0 a, oss ~ ~ ~~ o = lo- - ~ as 0 ~ c)
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From page 502... ...
502 a, o o ° o c ~ _' o .o ° o 0 As 0 o ~ 0 to z ~ c =~ ~ ~ ~ ~ o ~ ~ a_ ° to 8 ~ ~ ~.O Ed ~ to, '1 on ~ o o .,, 8~ .,, o a: 0 ~ V _ 0 1 ~ 8 x sOs o ~ fit.
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From page 503... ...
On the basis of controlling ambient sulfur dioxide concentrations, iche Tacoma TCS can be considered a success. Bowever, the system is designed to meet local standards as well; here reliability is nc'i adequate.
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From page 505... ...
·Without meteorologically~based controls, bob long and short-tare sulfur dioxide concentrations would have been dramatically higher during the 36-day 'period. ~ Percent reductions in average sulfa dioxide concentrations at the 17station ASARC'O monitoring network due to use of TCS controls ranged frown 27~9 to 6S.
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From page 506... ...
ret o ~ Al o ~ o ~ ~ ~ cn ram or o ·,1 ~ ~ an u]
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From page 507... ...
further evidence of the difficulty in meeting national AAQS with the El Paso ICS is provided by Table 12-7 {Helson 1974~. These data, derived from 13 stations in the ASARCO monitoring network which have operated continuously since 1970, indicate continuing violations of national AAQS.
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From page 509... ...
Jo ~ at.
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From page 510... ...
In general, currently operating systems provide significant reductions in peak ambient sulfur dioxide Concentrations measured near the emission source. However, all relevant ambient air standards are still not met ~ the vicinity of several of the sources which have implemented ICS technology, particularly the short-term local standards which are more stringent than the present Federal standards.
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From page 511... ...
e1 ;nd 511 monitoring capabilities to impl ement ICS controls. Generating Unit Availability The first of these issues can be partially assessed with 9~A data which forecast anticipated load reductions at 9 power plants if ICS measures are imposed through load shifting alone {Table 12-8} {qua 19731.
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From page 512... ...
- ~ o ~ Al - ~ ~ - ~ ~ x eq ~ dP 0 o a)
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From page 513... ...
{3} The ability to load switch is limited if large scale adverse met:eorology affects a large region rather than only one plant and one locality; the frequency of occurrence of this condition differs in various parts of the country. For example in the Tennessee Valley, 1WA has note-d 100 occasions since September 24, 1973 when the meteorological conditions appropriate for generation; reduction occurred at one or more of the following plants: Allen.
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From page 514... ...
{5} it is Important to note that the practicality of implementing TCS actions which demand load reductions can be questioned, since the desire to meet AAQS may conflict with- the desire of utilities to maintain an adequate power supply. for example, TvA has stated a...There are- two power system operational conditions in which the Paradise Steam Plant would not reduce generation load below a minimum level during a designated sulfur dioxide emission limitation period.
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From page 515... ...
Without ether complicating factors, Obese plants could presumably implement ICS programs which would feature relatively few emission reductions per year. Forecasting, modeling, and monitoring problems, although significant, would-be ~ minimized.
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From page 516... ...
Fuel switching will be practiced at Colbert, Cumberland, and Johnson~rille plants; load switching at Allen, Gallatin, Paradise, Shawnee, and Widows Creek plants; Kingston will rely on tall stacks alone. Operating costs presented in Table 12-1 1 include annualized capital charges, replacement power or low sulfur fuel charges for an equivalent of 107, 500 Manhours of electrical power, and operation-maintenance expenses.
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From page 517... ...
Reserve capacity of the TVA system would need to be increased if load switching were undertaken without purchase of replacement power from other utilities; capital and operating costs cited could be at least doubled i f reserve requirements on the order of 3- 4 percent of system load were required. Al so, the perkilowatt costs may be too low an estimate for other plants due to the large average size (about 1750 MW} of the TVA plants included in the nine plant network; tall stack costs and ICS program-monitoring costs should be relatively independent of plant capacity.
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From page 518... ...
Acceptance of the tall stack technology,. therefore' depends on a sob jective decision that the risks and uncertainties associated with potential environmental impacts due to these effects are outweighed by the incremental cost of continuous emission controls.
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From page 519... ...
. are not clearly related to ambient sulfur dioxide concentrations at individual locations and can be better desert-bed by the concentration of-total suspended particulate~natter~ and the general geographic locality-of the monitoring station.a ]
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From page 520... ...
operate the EGO systems; A} Tall stack-ICS technology is Capable of meeting existing ADS for sulfur dio-x~-de, -even in those situations where current emission regulations will not guarantee meeting ambient standards; 43} If ac~d-sulf:ate aerosols pose dangers to health, welfare:, -and aesthetics as suggested by EPA, ADOS for this class of pollutants should be established, following the procedures set forth in the ~ 970 Clean Air Act Amendmen;ts. If information regarding sulfates is not suf~cz;-~nt to issue ~ criteria document, then ~ tall: stack ICS technology should not be re jested on the basis of present information.
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From page 521... ...
'.' i; ~ ' '' '^ {1} Should tall stack-ICS technology be consider.'ea' es' a permanent emission control. technique?
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From page 522... ...
Tt would appear that the Ford A - inistration has recently adopted this position, in a November 22 statement of the Energy Resources Council. The Council agreed to support the policy of requiring continuous emission controls for all new and existing power plants, subject to deferral of compliance by those plants where implementation of ICS technology is deemed a feasible and enforceable alternative for meeting primary sulfur dioxide standards.
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From page 523... ...
Ambient standards are only a guide to the levels of emission controls which must be achieved by specific sources. Tn 1970, we recognized bat a control strategy based on a determ:`natzon of ambient air pollutant levels in relation to each individual source would be unenforceable.
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From page 524... ...
i.e., the geographic area within which emissions from a source may significantly affect the ambient air guality~a (4} Before approval of ICS controls will be granted, the emission source-must submit to the EPA Administrator a comprehensive report of a study which.de~onstrates the capability of the ICS, in conjunction with other control measures, to Beet ~ i ~ t air standa£ds~(FF 1974bl.
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From page 525... ...
{5} -Before approval of ICS controls can be grated, the emission source must :sub~nit to the Ad~ninis~ator an operational manual -lFR 1g74b} for t}~e-}C5 which ; Specifies number, type.-~-and location of ambient air quality Monitors. intestacy mo0tors, and meteorological instruments to-be us-cd.
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From page 526... ...
use of -tics] , the Administrator is ack~sawledging that e TO 3 can ins corporate-design and enforcement features that will prided reliable means to attain and maintain national sulfur dio~de standards.a C08tS of Monitoring and ~force~nt The monitoring and enforcement effort required of regulatory agencies to supervise implementation of ICS technology is greater plan that required for continuous emission controls.
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From page 527... ...
STATEMENT OF FINDINGS ED INCLUSIONS 1. Although current EPA regulations and the Energy Supply and Environmental Coordination Act of 1974 suggest a different interpretation, tall stack-ICS technology is considered here as a potentially important technological option for control of ambient sulfur dioxide concentrations.
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From page 528... ...
64 per cent Capital charges, additional reserve capacitye Operation and Maintenance Monitors & ICS Programs $2.1 million Stacks 0.9 millio;n .
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From page 529... ...
2. Tall stack dispersion is closely related to ICS control, since increased stack height decreases the need for intermittent emission reductions, assuming control of ambient sulfur dioxide concentrations is 1:he sole objective.
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From page 530... ...
8. This concept, i-f.adopted for eastern power plants with ICS controls, would severely limit potential applications of the technology.
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From page 531... ...
es is ~ of ICS programs.
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From page 532... ...
Based on TEA experience, with an expanded range of costs to account for Creased reserve requirements and application to smaller plants, costs can be expected to be as follows: Capital Costs: S4-10,kw Operating costs, including annualized capital charges: 0.15-0.4 mills,kwh Regulatory agency expenses for monitoring and enforcement of ICS programs represent hidden costs of control, not included in the above estimates. Defraying these costs by licensing and imposition of fees appears equitable.
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From page 533... ...
legal enforceability of these systems. Regulations proposed recently by SPA for ICS control emphasize enforcement of p.rescr~bed emission limitations included within an approved operational manual for each ISC systems in addition to enforcement based on-AAQS Enforcement based on this a - 1 strategy should be more effective than enforcement based on ARQS alone, since most of the critical elements- of the enforcement procedure can be established by the regulatory agency prior to approval of the ICS installation.
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From page 534... ...
An operating factor of 0.65 was assumed to compute costs per kwh. 8 miS concept, if adopted for eastern power plants with ICS controls, would severely limit potential applications of the ICS technology.
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From page 535... ...
{1974) Puget Sound Air Pollution COntrol Agency, Seattle, Washington, private communication, December Environment Reporter {1974} Train Reports Administration Accord on Permanent Controls for Power Plants, 5~32~: 1232-1233, December 6 Federal B~ergy`A~do~inistration (1974} Erie Clean Fuels Deficit -- A Clean Air AM Prob ends August.
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From page 536... ...
Frey { 1974) Tall Stacks and Intermittent Control of Sulfur Dioxide Emissions - TVA Experience and Plans, American Mining congress, Las Vegas, Nevada, October 7-1 0 .
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From page 537... ...
British Experience with Tall Stacks for Air Pollution Control on Large Fossil-Fuelled Power Plants, Combustion, 39:41-49, october. Tennessee Valley Authority (1973} Technical Presentation on TVA's Program for Meeting Ambient Sulfur Dioxide Standards, Chattanooga, Tennessee, September 14.
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From page 538... ...
S Environmental Protection Agency { 197 4b} National Strategy for Control of Sulfur oxides from Electric Power Plants, .
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